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The PFAS Drinking Water Rule Under the Second Trump Administration

Major trade associations and water systems filed suit to challenge the Biden-era U.S. Environmental Protection Agency's (EPA) National Primary Drinking Water Rule for six per- and polyfluoroalkyl substances (PFAS) under the...more

Impacts of a Trump EPA on Chemical Transporters' Reliance on In-Transit Exemptions

The global bulk chemical shipping industry relies on chemical transportation depots to be responsive to market demands by temporarily holding trailers and containers of chemical products en route to their final destinations...more

PFAS Designation Rule Will Impact Operational Compliance, Enforcement, Litigation and Policy

Although the U.S. Environmental Protection Agency (EPA) proposed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as the federal Superfund law (PFAS Designation Rule) in September...more

EPA Proposes Adding More PFAS to the Toxics Release Inventory

The U.S. Environmental Protection Agency (EPA) is proposing to add 16 new, individually listed per- and polyfluoroalkyl substances (PFAS) and 15 PFAS categories to the Toxics Release Inventory (TRI) list as "chemicals of...more

A Little Breathing Room for Product Importers: EPA Extends TSCA 8(a)(7) Reporting Deadline

While product importers were spending the summer poring over the Instructions for Reporting PFAS Under TSCA Section 8(a)(7) (May 2024), the U.S. Environmental Protection Agency (EPA) was working on a Direct Final Rule and...more

2024 Midyear PFAS Regulatory Update: Final Rules Recently Issued by EPA and What's to Come

Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more

Product Importers: Are You Ready for the New PFAS Reporting Requirements Under TSCA?

The U.S. Environmental Protection Agency (EPA) published a far-reaching and important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured and...more

Chemical Transporters Face Ongoing Challenges from EPA's Focus on "Transit-Related" Activity

Chemical transport, tank cleaning and transportation depot operators breathed a sigh of relief in March 2024 when the U.S. Environmental Protection Agency (EPA) dropped provisions from a proposed rule when it issued its final...more

EPA Designates 2 PFAS Compounds as Hazardous Substances

The U.S. Environmental Protection Agency (EPA) on April 19, 2024, announced its Final Rule designating two per- and polyfluoroalkyl substances (PFAS) compounds – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid...more

Senate Committee Convenes Hearing to Examine PFAS as Hazardous Substances

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on Sept. 6, 2022, to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), along with their structural isomers, as hazardous...more

New York State Issues Updated Soil Vapor Intrusion Guidance

The New York State Department of Health (NYSDOH) in late February 2024 announced an update to its Guidance for Evaluating Soil Vapor Intrusion in the State of New York. For the first time, the Soil Vapor/Indoor Air Decision...more

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more

2023 PFAS Year in Review: EPA Policy and Aqueous Film-Forming Foam Litigation Updates

2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more

EPA Publishes Comprehensive PFAS Reporting Rule Under TSCA

The U.S. Environmental Protection Agency (EPA) published a far-reaching and enormously important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured...more

Preparing for the Legal Effects of PFAS Legislation and Litigation on Your Business

Odds are that businesses involved in any kind of manufacturing or sale of physical products will be impacted by developments in legislation or case law involving per- and polyfluoroalkyl substances (PFAS). How big of an...more

EPA Releases Updated CERCLA Common Elements Guide - Enforcement Discretion Guidance Provides Important Direction on Landowner...

• The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) imposes strict, joint and several, retroactive liability on property owners and operators for releases of hazardous substances. However,...more

More Requirements and More Uncertainty - New York PFAS Update

By way of background, in 2016 the New York State Department of Environmental Conservation (NYSDEC) listed two long-chain per- and polyfluoroalkyl substances (PFAS)—PFOA and PFOS—as hazardous substances. However, NYSDEC did...more

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